Taxation of other income: taxable only in resident state, except income connected to permanent establishment or fixed base or gambling. Income of a resident not dealt with elsewhere in the Convention is taxable only in the resident State, subject to two exceptions: income (other than ... Summary
Taxation of other income: taxable only in resident state, except income connected to permanent establishment or fixed base or gambling.
Income of a resident not dealt with elsewhere in the Convention is taxable only in the resident State, subject to two exceptions: income (other than immovable property income) effectively connected with a permanent establishment or fixed base in the other State is taxable under the rules for business profits or independent personal services; and income from lotteries, betting, gambling and similar games sourced in the other State may be taxed in that source State.
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